Privacy Policy

YOUR PRIVACY IS PROTECTED

At PI Financial Corp. and at our subsidiaries* (collectively “PI ”), an important part of our commitment to provide you with service excellence is our respect for your right to privacy.

Keeping our customers' and employees’ information and affairs in strict confidence is a cornerstone of PI’s business. The range of products and services PI offers our customers continues to expand, and the technology we use continues to change. But, no matter how our business changes, we will always protect your privacy.

The policies and procedures which PI practices in order to protect your privacy are in place across our firm.

For purposes of this policy, "personal information" means information about an identifiable individual, but does not include the name or business contact information of that individual.

In the following pages we describe these policies and procedures and how PI puts them into practice so that you have control over how we collect, use and disclose your personal information.

Protecting Your Privacy Means:

PI keeps your personal information and the business you do with us in strict confidence

Your personal information is not sold to, rented to, leased to, or shared with, third parties without your consent

You have control over how PI obtains, uses, and gives out personal information about you

You have access to the personal information PI has about you

PI respects your privacy when we market our products and services

**OUR PRIVACY POLICIES PROTECT ALL OF OUR CUSTOMERS AND EMPLOYEES**

SECTION 1 - Accountability

PI is accountable for the protection of your personal information. While senior management is ultimately accountable for the protection of that information, the day-to-day monitoring for compliance may be delegated to staff.

While PI has procedures in place to assist our employees in the practice of the PI privacy policies, the overall responsibility for the protection of personal information, and compliance with this policy rests with PI’s Privacy Officer.

PI uses various third parties to process and store information. It is PI’s responsibility to ensure that the written contract with the outside party will afford a comparable level of protection while such third party is processing the personal information. This will usually mean the provision of a copy of this policy to such third party and the written acknowledgement from such third party that it will be bound by the policy. Further provisions include the return of all personal information to PI upon completion, an agreement not to use such information except for the purposes of PI ,and the destruction of any remaining records in the possession of the third party. Finally the third party must agree to advise PI immediately of any concerns, or objections expressed, relating to personal information of our clients and employees.

PI is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, in relation to e-mail or wireless communication, complete confidentiality and security is not assured.

PI is not accountable for any damages suffered when a customer or employee transmits personal information through e-mail or wireless communication or when PI transmits personal information to a client on request.

When opening an interest bearing or investment account, the Income Tax Act and other obligations require us to ask for your Social Insurance Number or other tax identification number

When opening an account that may hold U.S. securities or has U.S. beneficial owners, PI has contractual obligations with the U.S. Internal Revenue Service to ask for U.S. Taxpayer Identification Numbers and/or other citizenship or residential identification information

When opening an account, in order to assess your creditworthiness we ask you for certain financial information. For this reason, we may contact other lenders or credit bureaus to give us information on your credit history

For our employees - to provide benefits and manage the employment relationship

PI may review and analyze your use of products and services, including transactions in your accounts, to help protect you from unauthorized use of your accounts, to help us serve you better, to comply with our own supervisory requirements, and to bring other products and services to your attention which we feel will be of benefit to you. In this regard PI may monitor telephone communications from time-to-time.

PI collects, uses and discloses personal information only for purposes that a reasonable person would consider appropriate in the circumstances.

PI generally uses such personal information to carry on its business and serve its customers as described above. If the business is transferred to a new owner, the personal information will also be transferred subject to the limitations of Section 5.

SECTION 3 - Consent to Collection and Use

Your Consent

PI obtains your consent before we:

Check your employment

Obtain a credit report

Obtain, use or disclose to other persons, personal information about you unless PI is obliged to do so by law or to protect our interests

Use your personal information in any way PI didn't tell you about previously

Your Consent Can Be Express or Implied

Express consent can be verbal or written. For example, when applying for an account you give us your written consent for us to obtain a credit report.

You imply consent when PI can reasonably conclude that you’ve consented to the use of your personal information, through your action or inaction. For example, if in the course of your using your investment account, we are required to use an outside company to maintain your account data, we can conclude that you have consented to our providing your information to the outside company.

You Can Withdraw Your Consent After You’ve Given It

You can withdraw your consent any time after you've given it to us, provided there are no legal requirements to prevent this.

If you don't consent to certain uses of personal information, or if you withdraw your consent, PI may not be able to provide you with a particular product or service and we may not be able to provide service to you at all.

We Ask for Your Consent Before Using Information or Sharing Information with Other People

PI does not use personal information or release that information to anyone outside of PI without your consent.

There are some exceptions to the above rules. For example, PI may collect, use or disclose personal information without your consent if we:

Must use an outside company to process or store information
At times PI uses the expertise of an outside company to do work for us involving some of your information ­ for example, processing your account information or the mailing of shareholder information. When we use an outside company, we select the company carefully and confirm that it uses security standards comparable to those of PI .

Must disclose information for legal or contractual reasons
PI may be compelled to release your information by a court of law, or by another legal authority, regulatory authority, or governmental body. In any case, our policy is to release information only to the extent that we are required to do so.

For regulatory purposes, Canadian and United States self regulatory organizations including the Investment Industry Regulatory Organization of Canada, Bourse de Montreal Inc., the Toronto Stock Exchange, the TSX Venture Exchange, and the Canadian Investor Protection Fund, the Financial Industry Regulatory Authority Inc., the Securities Industry Protection Corporation (collectively, “SROs”) require access to personal information of current and former clients, employees, agents, directors, officers, partners and others that has been collected or used by persons or firms under their jurisdiction (“Regulated Persons”). SROs collect, use or disclose such personal information obtained from such Regulated Persons for regulatory purposes, including but not limited to:

Information-sharing with securities regulatory authorities, regulated marketplaces, other self-regulatory organizations and law enforcement agencies in any jurisdiction in connection with any of the foregoing.

We are also required under contractual agreement with the U.S. Internal Revenue Service to withhold taxes, and report certain account activity, for accounts that hold U.S. securities or have U.S. beneficial owners.

Must protect the interests of PI
In certain circumstances, PI may be required to collect, use or release information for its protection. For example, PI may do so when collecting an overdue account, when defending a legal action, to detect or prevent fraud, or to detect or prevent any other illegal or improper activity.

Are acting in a personal emergency

In certain circumstances, PI may be required to collect, use or release information where there is an emergency that threatens an individual’s life, health or personal security.

SECTION 4 - Limits For Collecting Personal Information

PI will only collect personal information for the purposes identified. PI will use methods that are lawful and will not collect that information indiscriminately.

Personal information will only be used or disclosed for the purpose for which it is collected. PI will not use personal information for any additional purpose unless we seek your consent to do so.

PI will not sell personal information to any third party but may transfer personal information to affiliated companies within the PI group.

Your Information is Destroyed When it is No Longer Needed

PI keeps your personal information only so long as we need it for the products and services you are using, to offer you products and services when you are a customer, to protect the interests of PI , or to meet any legal or regulatory requirements. Please note that PI retains your information for a significant period of time in order to assist you in reviewing your account history when necessary.

Sale of Business

One of the purposes for which PI collects, uses and/or discloses personal information is the operation of its business. In the event that all or part of the assets of PI are sold to a new owner, all personal information, or that part of the personal information associated with the assets being sold, will be transferred (disclosed) to the new owner, subject to certain conditions. Either the new owner must agree to maintain and abide by PI’s then existing Privacy Policy for a minimum of six months, or the new owner must agree to PI sending notices to all of its current customers advising them of the proposed transfer, the new owner's privacy policy and providing its customers with an easy and effective means of withdrawing their personal information from the transfer, at PI’s option.

SECTION 6 - Accuracy

PI will make reasonable efforts to ensure that personal information is as accurate, complete and current as required for the purposes for which it was collected. In some cases, PI relies on its clients and employees to ensure that certain information, such as their address or telephone number, is current, complete and accurate.

PI will not routinely update personal information unless it is necessary to fulfill the purposes for which it was collected or if it is required to maintain an active account.

You can check your information to verify, update and correct it, and to have any obsolete information removed. PI may ask you to put your request in writing. If there is any dispute about your request, PI will note your opinion on the file. There is no charge for verifying or correcting your information but PI Financial may charge a reasonable fee for accessing the information.

You can check much of your personal information routinely, for example, by carefully examining your account statements and confirmation slips.

SECTION 7 - Safeguarding Personal Information

We Protect Your Information From Error, Loss and Unauthorized Access

PI is committed to the safekeeping of personal information in order to prevent loss, theft, unauthorized access, disclosure, duplication, use or modification. Our employees who have access to personal information are made aware of its confidentiality.

Depending on the sensitivity of the information. PI will employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices and storage facilities or electronic security measures such as passwords, encryption and personal identification numbers. This protects your information when it is stored in data files or handled by our employees. Our systems also protect your information when it is transmitting data, for example, between PI and our third party data providers.

PI will use appropriate security measures when disposing of personal information.

Continuing Security Policy Development

The development of PI’s policies and procedures for the protection of personal information is an ongoing process. PI is committed to developing, updating, and reviewing our information protection controls to ensure ongoing security.

SECTION 8 – Availability of Policies and Procedures

PI is open about the policies and procedures it uses to protect personal information. Information about those policies and procedures will be made available either electronically or in written format in plain language. However, to ensure the integrity of our security procedures and business methods, PI may refuse to publicly disclose certain information.

PI will make the following information available:

The name, title, and address of the Privacy Officer

The means by which you can obtain your personal information

A description of the type of personal information held by PI including a general account of its use

A copy of any brochures or other information that explain the policies and procedures

An explanation of what personal information is made available to other organizations such as our affiliated companies

SECTION 9 - Access to Personal Information

You have the right to access the personal information held by PI . Upon request, PI will, within a reasonable time period, tell you what personal information it has, what it is being used for, and to whom it has been disclosed if applicable within the time period for which records are available.

If you have a sensory disability, PI will give you access to your personal information in any alternative format you request if we already have it in that format or if its conversion into that format is reasonable and necessary in order for you to be able to exercise your rights under applicable legislation.

You may be asked to be specific about the information you would like to access and to submit your request in writing to your contact at PI . You may be asked to provide personal information to identify yourself prior to the release of personal information pursuant to a request.

If you ask, PI will let you know the names of outside companies or organizations we may have given information to in the normal course of providing services to you. If PI has obtained information about you from other people, upon your request we will let you know the person we got it from.

In certain cases, PI may not provide access to any, or all, personal information about you. For example, PI may not be able to precisely document information given to outside companies or organizations PI has used to do work for us on an integrated basis, such as our data providers, in the normal course of providing services to you. PI will also not document reports to the Canada Customs and Revenue Agency or other taxation reports, or information PI has provided under a lawful duty of non-disclosure, under solicitor-client privilege, or under other legal privilege. In such cases, PI will explain the reasons it will not provide the requested information.

Depending on the circumstances, you may be charged a reasonable fee if you want a copy of records which PI has already given you ­ for example, an account statement. PI will let you know in advance if there is a charge.

We Will Respond to Your Request Promptly

PI will deal quickly with your request to see your information, and almost always respond to you within 30 days. If we need to extend the time, or we must refuse your request, we will tell you why, subject to any legal restrictions and we will notify you of the new deadline, the reasons for the extension, and of your right to make a complaint to the Privacy Commissioner regarding the extension.

We Protect Other People’s Privacy When We Make Information Available to You

There may be files that include information about you and other customers, or that have information confidential to PI or are the property of PI . Because we must respect everyone's confidentiality and legal rights we cannot make these files available to persons outside of PI . However, PI will make available to you any factual information about you contained in such files.

SECTION 10 - Compliance and Complaints

If you have any questions or complaints about our privacy policies, or about how PI is living up to them, let us know right away.

Resolving Your Concerns is Important to Us

PI is committed to treating you with the greatest respect and consideration, and to providing the highest level of service. Even so, from time to time something may go wrong. There may be a misunderstanding, or you may feel you have been dealt with unjustly. Whatever the circumstances, resolving the problem for you is our primary concern.

How to Resolve Privacy Concerns and Compliants at PI

In general, the persons to contact are as follows:

Your Investment Advisor

The Privacy Officer at Head Office

CEO

At any time you may also write to the Privacy Commissioner

We expect every PI employee who receives a written customer complaint to take action, and ensure that the complaint is resolved in a timely manner.

Talk to Us

In most cases, a complaint can be resolved simply by telling us about it and discussing it with us.

If You Are Not Satisfied with PI’s Decision Regarding Your Complaint…

Should you not be able to accept PI’s conclusion, or any time in the process, you may also write to the provincial Privacy Commissioner, or if applicable, the Privacy Commissioner of Canada. PI will provide you with this contact information upon request.

Changes

From time to time PI may make changes to this policy to adapt to changing business conditions and for other reasons. In the event that in the opinion of PI acting reasonably such changes will allow PI to make materially greater use and/or disclosure of any personal information, the individuals affected by the changes will be clearly and concisely notified of the changes and their proposed effect, and provided with an opportunity to withdraw their consent to the collection, use and/or disclosure of their personal information.

PI Financial Corp. is licensed as a broker-dealer in all provinces and territories of Canada and is a member of the IIROC and the Canadian Investor Protection Fund. The contents of our Website are not intended, and should not be construed, as a solicitation of customers or business in any jurisdiction in which we are not registered as a dealer in securities